Last updated: January 8, 2025
This Privacy Policy explains who we are, how we collect and process your personal data, and how you can exercise your privacy rights. The terms “personal data” and “personal information” are used interchangeably in this Policy.
This Policy applies exclusively to your interaction with the Thinking Lens website at www.thinkinglens.app (”Website”). For the avoidance of doubt, this Policy does not apply to your use or access to the Thinking Lens app.
This policy complies with the General Data Protection Regulation (GDPR) and other relevant privacy laws. We recommend that you read this Policy in full as it contains descriptions as to our personal information processing practices and explanations of your legal rights. To make this Policy easier for you to review, we have divided the document into following sections:
1. Who we are
2. What personal information we collect
3. How we use your personal information
4. Your rights under data protection laws
5. Cookies and other online tracking technologies
6. General information
1. Who we are
Thinking Lens is a mental health technology company based in the United States, developing a mental wellbeing app called Thinking Lens.
For residents of the European Economics Area or other jurisdictions with laws applicable to the processing of your information, please be aware that your personal data will be transferred to and processed in the United States, where our servers and service providers are principally located. By providing us your personal data, you consent to the transfer and processing in accordance with this Policy.
2. What personal information we collect
2.1 Information you provide voluntarily
Through our Website, you may apply to be a Beta User, as defined in the Thinking Lens Waitlist Terms & Conditions (“Waitlist Terms”). The personal data we collect from you may include:
- Your email address; and
- Information about your device’s operating system (to ensure compatibility for beta testing).
2.2 Information we collect automatically
When you visit or interact with our Website, certain information is automatically collected through your browser or device. This information is generally non-personally identifiable. We refer to this data as "usage data," and it includes:
- The time spent on the Website;
- The pages visited and links clicked; and
- The country from which your browser is accessing the Website.
We use Google Analytics to collect the above information. Please see section 5 of this Policy for more information.
2.3 Information we collect from other sources
Apart from what is disclosed in section 2.2 and section 5, as of the Effective Date of this Policy, Thinking Lens does not collect your personal information from any third parties.
3. How we use your personal information
3.1 We process your personal information for the following purposes:
- To provide, operate, and maintain the Website;
- To respond to your inquiries, fulfill your requests, and communicate with you regarding your presence on the Waitlist;
- To send marketing materials related to our products or services (only where we have your consent or legitimate interest to do so); and
- To send you administrative communications, including updates to our Website or changes to our terms.
3.2 Personal information retention periods
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize such data.
If you elect to receive notifications about Thinking Lens from us, we will store the relevant information until you unsubscribe.
If you apply to be a Beta User, as that term is defined in the Waitlist, your data will be stored until it is no longer required for such purpose or until you request Thinking Lens delete it, or until you revoke your consent.
4. Your rights under data protection laws
Under data protection laws, including the General Data Protection Regulation (GDPR) for EU residents, you have the following rights regarding your personal data. To exercise these rights, please contact us at founders@thinkinglens.app:
- The right to request access to the personal data we hold about you;
- The right to request rectification of inaccurate or incomplete data;
- The right to request erasure of your personal data, subject to certain exceptions (e.g., for legal compliance or legitimate interests);
- The right to request restriction of processing if you contest the accuracy of your data;
- The right to receive your personal data in a structured, machine-readable format, or to transfer it to another entity;
- The right to withdraw your consent to processing at any time, where consent is the legal basis for processing;
- The right to not be subject to automated decision-making, including profiling; and
- The right to lodge a complaint with a supervisory authority.
5. Cookies and other online tracking technologies
Cookies are small text files placed on your device to store data that can be recalled by a web server. While Thinking Lens does not use cookies for tracking or advertising, we do use Google Analytics to monitor how visitors use our Website and to improve its performance. Google Analytics may collect data such as your location, device, and browsing behavior. For more information about how Google collects and uses data, please see Google’s Privacy Policy. You can opt-out of Google Analytics by visiting Google Analytics Opt-Out.
6. General information
6.1 Children’s policy
Our Website is not intended for use by children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected data from a child under 16, we will take steps to delete that information.
6.2 Securing your personal information
We, and our service providers, use commercially reasonable practices to safeguard and secure your personal information.
6.3 Changes to this Policy
Thinking Lens will review and update this Policy periodically and will note the date of its most recent version above. If we make material changes to this Policy, we will notify you either by prominently posting a notice of such changes prior to implementing or directly sending you a notification.
6.4 Contact informationIf you have any questions or concerns about this Privacy Policy, please contact us at founders@thinkinglens.app.